AT&T Statement on FCC’s Outage Reporting Rules for Submarine Cables

“Submarine cable facilities have important national security and commercial implications. For this reason, a coalition representing cable providers sought to give the FCC constructive input on a meaningful yet reasonable cable outage reporting framework. Today’s order, however, perpetuates flawed assumptions from the recent Part 4 Order on terrestrial facilities – such as requiring outage reports for events that simply affect redundancy of service – and woefully underestimates the costs and burdens of compliance. These new regulatory requirements and deadlines will do little to enhance the resiliency of submarine cable facilities.

“Under this new regulatory regime, providers will be required to file an initial report within eight hours of determining that an outage is reportable, decreasing to four hours over time, and an interim report within 24 hours of receiving a cable repair plan. International undersea cables, which are often jointly managed by a large number of companies from many different countries, extend from continent to continent and are not easily accessible. The adopted intervals for the initial report are insufficient given the logistical issues associated with international operations and the significant amount of coordination necessary amongst companies. And changing the interval over time needlessly increases the costs and complexity of implementing the new requirements.

“Further, the order’s conclusion that these new reporting requirements be implemented within six months is unreasonable and disregards industry input. Given the amount of coordination, and investments in new technology for older submarine cables necessary to implement a new reporting system, members of the industry had sought as much as 18 months to put the new framework in place. AT&T anticipates that it will require much longer than six months for many of our submarine cables, which are older and jointly owned with multiple foreign partners.

“This new framework will impose substantial costs and burdens on providers without identifying corresponding benefits during times when the principal objective should be repairing the undersea cable facilities, not completing unnecessary and redundant reporting to the government.”

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